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Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562

Facts

Anthony Faretta was charged with grand theft in California. Before his trial, he requested to represent himself, believing the public defender's office was overwhelmed. The trial judge initially accepted his waiver of counsel but later reversed this decision, ruling that Faretta could not adequately represent himself. Throughout the trial, Faretta was required to be represented by the public defender, leading to his conviction.

Faretta clearly and unequivocally declared to the trial judge that he wanted to represent himself and did not want counsel. The record affirmatively shows that Faretta was literate, competent, and understanding, and that he was voluntarily exercising his informed free will.

Issue

Does a defendant in a state criminal trial have a constitutional right to represent himself when he voluntarily and intelligently chooses to do so?

The question before us now is whether a defendant in a state criminal trial has a constitutional right to proceed without counsel when he voluntarily and intelligently elects to do so.

Rule

The Sixth Amendment, applicable to the states through the Fourteenth Amendment, guarantees a defendant the right to self-representation in a criminal trial.

The Sixth Amendment includes a compact statement of the rights necessary to a full defense: 'In all criminal prosecutions, the accused shall enjoy the right . . . to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defence.'

Analysis

The Supreme Court analyzed the right to self-representation as implied by the structure of the Sixth Amendment. It emphasized that forcing a lawyer upon a defendant who wishes to represent himself violates this constitutional right. The Court found that Faretta had clearly expressed his desire to represent himself and was competent to make that choice, thus the state courts erred in denying him that right.

In forcing Faretta, under these circumstances, to accept against his will a state-appointed public defender, the California courts deprived him of his constitutional right to conduct his own defense.

Conclusion

The Supreme Court vacated the judgment of the lower courts and remanded the case, affirming Faretta's constitutional right to conduct his own defense.

Accordingly, the judgment before us is vacated, and the case is remanded for further proceedings not inconsistent with this opinion.

Who won?

Anthony Faretta prevailed in the Supreme Court, as the Court recognized his constitutional right to self-representation, which had been denied by the state courts.

In vacating the judgment, the Court recognized that forcing a lawyer upon an unwilling defendant is contrary to his basic right to defend himself if he truly wants to do so.

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